IE Circular No. 77-04 - Inadequate Lock Assemblies

CR77004
March 17, 1977
MEMORANDUM FOR: J. P. O'Reilly, Director, Region I
N. C. Moseley, Director, Region II
J. G. Keppler, Director, Region III
E. M. Howard, Director, Region IV
R. H. Engelken, Director, Region V
FROM: N. H. Haller, Assistant Director for Safeguards
SUBJECT: IE CIRCULAR NO. 77-04- INADEQUATE LOCK ASSEMBLIES
REFERENCES: IE Circular No. 76-08 of December 22, 1976, Inadequate
Vital Area and Material Access Area Lock Assemblies
The reference cited above, less its Appendix A which was forwarded by
separate means, is hereby cancelled and superseded. All copies of the
reference are to be destroyed.
The superseding Circular, No. 77-04, Inadequate Lock Assemblies, of March
17, 1977, is enclosed for your distribution with the Appendix A to all Group
I, II, IV and V licensees within your Region.
A sample transmittal letter to each licensee is provided.
Norman Haller, Assistant Director
for Safeguards
Office of Inspection and Enforcement
Enclosures:
1. Trans. ltr to Licensees
2. IE Circular 77-04
Inadequate Lock Assemblies
.
(Transmittal Letter For IE Circular 77-04 To Each Safeguards Group I, II, IV
and V Licensee)
Addressee:
The enclosed IE Circular, 77-04 is forwarded for your information and use.
The subjects covered by this Circular should be helpful to you in properly
implementing the physical security systems needed for your facility to meet
the requirements of 10 CFR Part 73. The illustrated Appendix is provided for
the sake of clarity and does not constitute an endorsement of any
manufacturer's specific product.
No written report to the NRC is required by this Circular. If you have any
questions concerning this matter, contact the Director of this NRC Regional
Office.
Regional Director
Enclosure:
IE Circular 77-04
Inadequate Lock Assemblies
with Appendix A
.
Nuclear Regulatory Commission
Office of Inspection and Enforcement
Washington, D. C. 20555
IE Circular No. 77-04 Date: MAR 17 1977
Page 1 of 3
INADEQUATE LOCK ASSEMBLIES
DESCRIPTION OF CIRCUMSTANCES:
During recent physical security inspections at nuclear fuel cycle and
reactor facilities, it was discovered that the lock assemblies securing some
material access areas and vital areas were inadequate, improperly installed,
or inoperable for a lack of maintenance. In a number of instances, the
deficiencies were cited as items of non-compliance. The specific findings
included:
(a) Doors secured only with locks having simple spring latches which
could be readily depressed with a piece of plastic, a card, knife,
or other thin instrument.
(b) Doors secured with locks having dead latches which were
ineffective due to poor installation or lack of maintenance. The
installation tolerances for a dead latch are very critical and
their anticipated service life quite limited.
(c) Outswinging doors and inswinging double-doors without mullions,
which were not equipped with astragals or guard plates to deter
forcible attacks upon the latch or bolt.
(d) Exterior or exposed lock cylinders which were not equipped with
effective collars or cylinder guards to deter forcible attacks
upon the cylinders.
(e) Doors secured only by lock sets with cylinders mounted within the
door knobs, making the doors very vulnerable to forcible attack.
(f) Lock sets which did not engage their associated strike plates due
to incorrect installation, adjustment, maintenance, or damage.
(g) Doors without locks.
.
IE Circular No. 77-04 Date: MAR 17 1977
Page 2 of 3
DISCUSSION:
10 CFR 73.2 (f) (2) requires that openings in building walls be of
construction and fastening of sufficient strength so that the integrity of
the wall is not lessened by the opening. This requirement extends to vital
areas (10 CFR 73.2(h)) and material access areas (10 CFR 73.2(j)). Thus,
door locks must be of substantial construction and of such design,
installation, and reinforcement that their neutralization or circumvention
by common burglary techniques is precluded. Regulatory Guide 5.12, the
Federal crime insurance guidelines, recent municipal codes and ordinances,
and generally accepted practices within the profession of industrial
building design and construction, advise that doors must be secured with a
dead bolt. Further, in recognition of widely disseminated and publicized
simple burglary techniques which can be accomplished with common tools
without skill, the following limiting factors must be considered in
determining whether the integrity of a vital area or material access area
wall is maintained:
(a) The door is secured with a dead bolt with either a one inch
lateral throw or multiple-vertical engagements with its strike.
(b) Outswinging doors and inswinging double-doors without mullions,
are equipped with securely mounted astragals or guard plates.
(c) Exterior or exposed cylinders are rim, bored-auxiliary, or mortise
lock mounted, and are protected with (1) a cylinder guard or (2)
substantial collar which is tapered, extends beyond the face of
cylinder, and rotates independently when torque is applied.
(d) All lock sets and associated hardware are effectively installed
and maintained.
Hardware illustrations and standard lock terminology are enclosed as
Appendix A.
.
IE CIRCULAR No. 77-04 Date: MAR 17 1977
Page 3 of 3
POSSIBLE SOLUTIONS:
The identified generic deficiencies may be eliminated by the comprehensive
implementation of one or more of the following solutions, in consonance with
the operational and safety considerations of the facility.
(a) Institute measures to assure conformance with the four limiting
factors cited in the Discussion paragraph, above.
(b) Obviate lock inadequacies by barring the door from within with a
wooden (min. 2" x 4") or pipe (min. 2" dia.) member extending
solidly across both stiles and jambs.
(c) Obviate lock and other possible deficiencies by eliminating the
doorway and filling the resulting cavity with masonry or
construction materials equal to or exceeding the composition of
the wall.
This information is provided for action you deem appropriate to insure that
vital area and material access area doors are secured in a manner which does
not lessen the integrity of the walls and other physical barriers.